By William Kelly and Simon Riveles On May 24, 2016, the Securities and Exchange Commission (“SEC”) published a notice of its intent to issue an order increasing the net worth threshold for “qualified clients,” as defined in Rule 205-3 under the Investment Advisers Act...

By William Kelly On August 25, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) proposed a new rule applicable to investment advisers. At its core, the proposal seeks to extend anti-money laundering (“AML”) obligations imposed under the Bank...

Background In a post Dodd-Frank world, compliance is king. For the founder of a new hedge fund, compliance with the new Investment Advisers Act (the “Advisers Act”) registration regime is a critical initial step. If registration is required, investment advisory...